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Agriculture employees entitled to overtime, SJC holds.

Whether employees are entitled to overtime pay is a question that courts frequently grapple with because many employers seek to avoid paying time-and-a-half when they can.

Recently, the Massachusetts Supreme Judicial Court weighed in on this topic and ruled that employees who cleaning, packaged, and distributed agriculture products in Massachusetts were entitled to receive overtime pay when they worked more than 40 hours in a workweek.

In that case, Arias-Villano v. Chang & Sons Enterprises, Inc., the employer argued that the employees were not entitled to overtime pay because the Massachusetts overtime law does not apply to employees "engaged in agriculture and farming on a farm." The Supreme Judicial Court rejected this argument unanimously, ruling that the so-called "agriculture exemption" applies only to workers involved in planting, raising, and harvesting crops. Because the employees in Arias-Villano did not actually plaint, raise, or harvest crops, the employer owed them overtime.

In reaching that decision, the Supreme Judicial Court emphasized that the Massachusetts overtime law serves three purposes: "to reduce the number of hours of work, encourage the employment of more persons, and compensate employees for the burden of a long workweek." It also held that its decision was consistent with the plain language and legislative intent of the agricultural exemption, which was to address industry concerns that a 40-hour workweek was "impractical given the time-sensitive nature of growing and harvesting perishable fruits and vegetables." 

You can read the full decision in Arias-Villano v. Chang & Sons Enterprises, Inc., here.

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